In this five-part podcast series, sponsored by Assent Compliance Inc. (Assent), I explore market impacts of emerging regulations on supply chain compliance and the supply chain professional. During the course of this series, I visit with several members of the Assent team to introduce the topic, look at Human Trafficking and Slavery (HTS), supply chain risk management programs, CSR value propositions, the current state of responsible mineral sourcing and scaling up to meet future challenges. In episode one, I visit with Kate Dunbar, subject matter expert for Assent Compliance in HTS on the current and evolving HTS landscape. Join us tomorrow where provide an overview of instituting a broader supplier risk management program. You can check out more about Assent Compliance Inc. at their website, by clicking here.
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In this episode I visit with Mark Lanpher, a partner at Shearman & Sterling LLP, practicing in the firm’s White Collar and Regulatory Enforcement group. Lanpher is a former Assistant Chief Litigation Counsel at the SEC. We take a deep dive into the July 2018 change in FCPA Enforcement Policy, announced by the Justice Department creating a safe harbor in mergers and acquisition enforcement actions brought under the FCPA. Some of the highlights from the podcast include:
- How did Matthew Miner’s announcement impact the FCPA Corporate Enforcement Policy re: M&A?
- What were the policy reasons behind the announcement?
- Was Miner’s announcement a codification of DOJ/SEC safe harbor policy first articulated in the 2012 FCPA Guidance?
- How did (or not) Miner’s announcement bring certainty to this area?
- What does it mean going forward?
Books reviewed in today’s edition of Daily Compliance News:
- Leadership and the Rise of Great Powers-Yan Xuetong
- China and Japan: Facing History-Ezra Vogel
- China’s Vision of Victory-Jonathan DT Ward
In today’s edition of Daily Compliance News:
- FIFA VP detained for questioning by French Police.(NYT)
- In the UK, expect fines to increase under GDPR. (Compliance Week)
- Want to go the ISS? NASA has a ticket for you (limited leg room in coach) (NYT)
- What happens when new CEO throws old CEO ‘under the bus’? Meg Whitman explains. (FT)
In today’s edition of Daily Compliance News:
- OSI announces both DOJ and SEC have dropped their FCPA investigations of the company? (YaHooFinance)
- Fiat Chrysler’s U.S. Sales Chief Files Whistleblower Lawsuit. (WSJ)
- Will JPMorgan settlement lead to increase in Dad-leave? (Washington Post)
- SEC investigating Siemens AG, Philips NV and General Electric Co for FCPA violations. (Reuters)
As the enjoy the Astros continue their decimation of their AL West opponents and the lads celebrate finally getting their own iTunes show, they return to discuss both events some of this week’s top compliance and ethics stories which caught their collective eyes.
1. Complexity and compliance, how do you deal with this in your compliance program?
2. The SEC gives two whistleblowers a premium for reporting internally before disclosing to regulators.
3. Wither CITGO? Tom predicts things will go downhill quickly in a FCPA kind of way.The next day the government announces a subpoena to CITGO for potential FCPA violations.
4. The Malaysian Anti-Corruption Commission on extending the commitment of management to do business in compliance and ethically.
5. Managing Anticorruption Compliance Under the EU’s General Data Protection Regulation. An article by Ruta Mrazauskaite.
6. Is Exxon evil? Jaclyn Jaeger thinks so and explains why in an Op-Ed.
7. Mike Volvok follows his 3-part series on auditing your investigative protocol with a 4-part series on a sanctions compliance program.
8. Why is compliance is critical in the daily changing Trump trade wars against everyone. Paul Ziobro reports on FedEx.
9. Why a ‘necessary evil’ does not constitute effective compliance. Mary Bennett explains.
10. ESG Screening Underscores Challenges in Third-Party Risk Management. Brian Alster considers.
11. This week Tom had a special 5-part podcast series sponsored by AMI on the new Justice 2019 Guidance featuring Eric Feldman. Check out the following: Part 1-Introduction;Part 2-Well-designed;Part 3– Effectively Implemented; Part 4-Working in Practice; Part 5-Final Thoughts. The podcast is available on multiple sites: the FCPA Compliance Report, iTunes, JDSupra, Megaphone,YouTube, Spotifyand Corporate Compliance Insights. The Compliance Podcast Networkjoins C-Suite Radio.
12. Join Tom in Boston for his industry leading Compliance Master Class on June 11 & 12. Listeners who attend will receive a complimentary copy of The Compliance Handbook. Registration and Information is here. Join Tom, Eric Feldman, Vin DiCianni and Jay at the AMI Roundtable in Boston on June 13 for a deep dive into the DOJ’s new Evaluation of Corporate Compliance Programs-2019 Guidance. Information and registration is here.
Tom Fox is the Compliance Evangelist and can be reached at tfox@tfoxlaw.com. Jay Rosen is Mr. Monitor and can be reached at jrosen@affiliatedmonitors.com.
Tom Fox is the Compliance Evangelist and can be reached at tfox@tfoxlaw.com. Jay Rosen is Mr. Monitor and can be reached at jrosen@affiliatedmonitors.com.
In this podcast, data privacy/data security expert Jonathan Armstrong and Compliance Evangelist Tom Fox use the framework of GDPR to discuss a wide range of issues relating to these topics. They consider what the US compliance and InfoSec security expert needs to know about what is happening in the UK, Europe and beyond. This episode is the first of a two-part series where Jonathan Armstrong and myself consider some of the highlights from the first year of GDPR implementation and enforcement. In this Part I we considered some of the enforcement numbers. In this Part II, we discuss some of the substantive issues. Some of the highlights in this episode include:
- Security issues-multiple regulators for large breaches and questions of whether TOMs are adequate.
- 6 Principles of GDPR-highest is around transparency.
- Data Subject Rights are seen as the biggest corporate pain points.
- DPIAs have been embraced by many companies and are seen by regulators as the backbone of a corporate compliance program around data security/data privacy.
- Industry sweeps are beginning to occur.
- Mixed quality of legal advice is hurting many companies in their compliance efforts.
- Some significant cases are headed to trial and then appeal.
- GDPR is here to stay.
For more information on Cordery Compliance, go their website here.
For additional reading see the Cordery Compliance article, “GDPR One Year On”.
Also check out the GDPR Navigator, one of the top resources for GDPR Compliance by clicking here.
In today’s edition of Daily Compliance News:
- VW says it wants to stop cheating?(NYT)
- Mario Rubio says you can’t trust a Chinese audit. (WSJ)
- Is it compliance or is it customer relations? Uber may fire you as a customer.(WSJ)
- What does the 2019 Guidance mean for Boards of Directors. (Harvard Law School Forum on Corporate Governance and Financial Regulation)
In today’s edition of Daily Compliance News:
- KPMG Director accused of bullying steps down?(FT)
- The SFO fines F.H. Bertling Ltd. £850,000 for role in Angola bribery. (WSJ)
- SEC files charges against unregistered $100 million crypto token offering.(MarketWatch)
- SEC issues joint whistleblower award. (FCPA Blog)
Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I go into the weeds to explore how the complexity of modern-day corporations can lead to catastrophic failures such as the two crashes of the Boeing 737 Max.
Some of the highlights include:
- Our podcast today was based upon two blog posts we both wrote this week based upon the NYT article The Late Change, and Fatal Flaws in Boeing’s Plane.
- Why and how can complexity lead to catastrophic failre?
- The modern corporation is very siloed. How does this contribute to risk?
- Why every compliance professional should read the NYT article.
- How should you think about systemic risk in your organization’s ecosystem?
- How does the COSO 2013 Internal Controls Framework consider the issue of communication across an organization?
In addition to the great NYT piece check out the following resources:
Matt’s blog post-Another Lesson from Boeing-Silos
Tom’s blog post-Boeing and More Compliance Lessons